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2.4.2 Do the current third party arrangements add value to the metrological system?
Do they impose unnecessary regulatory burden? - Open text field for response
Yes. They provide a framework from which to ensure that Legal Metrology requirements are being met. (With jurisdiction over areas not covered by ISO17025 accreditation). Current arrangements are not onerous.
5.2.1 Should the current system for UMVs be maintained and why? What is the value UMVs
provide to businesses and to the community? - Open text field for response
The current system (including NITP14) defines requirements to ensure a consistent approach to verification of utility meters and should be maintained. The existing prescriptive approach is beneficial as it:
a. Assists new (and existing) manufacturers/suppliers to ensure Utility Meters are meeting a minimum level of performance.
b. Transparently demonstrates to consumers (such as public utilities) how utility meters are confirmed to conform with performance requirements.
c. Provides an auditable framework to assess a UMV.
The current system for UMVs is much more important to the community than Pattern Approval (which only confirms only that “one-off” special samples conform to design requirements). UMVs ensure that the ongoing production of utility meters meet a minimum level of performance.
5.2.3 How can the process of appointment for UMVs be improved? How appropriate,
effective and efficient are the current requirements and conditions for appointment as a
UMV? - Open text field for response
There are minimal compliance assessments for UMVs. Enforcement and escalation options exist but appear to rely on a reported breech before compliance to the measurement framework is assessed.
Suggestions to encourage compliance to obligations include:
- Workshops and forums for UMVs (eg once every 2 years) to promote education and discussion of specific UMV requirements.
(existing requirements to attend legal metrology workshops are ineffective as these are too general and don’t address specific UMV activities)
Administrative options to ensure compliance could also include informal site visits to UMVs (Once per term of appointment) This would have the objective to identify any non-compliant activities before they escalated into Medium or High risk.
5.2.4 What is the appropriate level of competency that should be required for a UMV? Is the
current accreditation requirement appropriate, effective and efficient? - Open text field for response
UMVs should be competent in complying with Australian Legal Metrology requirements. ISO17025 certification is an indication of competency in implementing ISO17025 but does not demonstrate competence in Legal Metrology. Current requirements are insufficient to ensure the competency of a UMV to implement Legal Metrology requirements.
5.2.5 What is the appropriate form of ongoing monitoring and auditing of a UMV? - Open text field for response
A formal auditing scheme may be overburdensome, but reviewing the competence of a UMV could be achieved without undue burden, by requirements such as:
o Annual declaration of quantities of meters verified
o Providing examples Verification documentation
- Certificates of Verification,
- Test data,
- Certification of facilities conducting testing (ISO17025)
o Company procedures for conducting verification activities.
7.2.5 How important is the appointment as an LMA to your business? What percentage of
your business involves carrying out LMA functions? - Continue or submit
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